RELIABILITY | RESILIENCE | SECURITY Actions...of its Facility Ratings Methodology met all documented requirements. The violation posed a serious risk to the reliability of the bulk

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RELIABILITY | RESILIENCE | SECURITY

December 30, 2019 VIA ELECTRONIC FILING Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, DC 20426 Re: NERC Full Notice of Penalty regarding Bonneville Power Administration,

FERC Docket No. NP20-_-000 Dear Ms. Bose: The North American Electric Reliability Corporation (NERC) hereby provides this Notice of Penalty1 regarding Bonneville Power Administration (BPA), NERC Registry ID# NCR05032,2 with information and details regarding the nature and resolution of the violation3 discussed in detail in the Settlement Agreement attached hereto (Attachment A), in accordance with the Federal Energy Regulatory Commission’s (Commission or FERC) rules, regulations, and orders, as well as NERC’s Rules of Procedure including Appendix 4C (NERC Compliance Monitoring and Enforcement Program (CMEP)).4 NERC is filing this Notice of Penalty with the Commission because Western Electricity Coordinating Council (WECC) and BPA have entered into a Settlement Agreement to resolve all outstanding issues arising from WECC’s determination and findings of the violation of FAC-009-1 R1.

1 Rules Concerning Certification of the Electric Reliability Organization; and Procedures for the Establishment, Approval, and Enforcement of Electric Reliability Standards, Order No. 672, 114 FERC ¶ 61,104, order on reh’g, Order No. 672-A, 114 FERC ¶ 61,328 (2006); Notice of New Docket Prefix “NP” for Notices of Penalty Filed by the N. Am. Elec. Reliability Corp., Docket No. RM05-30-000 (February 7, 2008); Mandatory Reliability Standards for the Bulk-Power System, Order No. 693, 118 FERC ¶ 61,218, order on reh’g, Order No. 693-A, 120 FERC ¶ 61,053 (2007).

2 BPA was included on the NERC Compliance Registry as a Balancing Authority (BA), Planning Authority/Planning Coordinator (PA/PC), Resource Planner (RP), Transmission Owner (TO), Transmission Operator (TOP), Transmission Planner (TP), and Transmission Service Provider (TSP) on June 17, 2007.

3 For purposes of this document, each violation at issue is described as a “violation,” regardless of its procedural posture and whether it was a possible, alleged, or confirmed violation.

4 See 18 C.F.R § 39.7(c)(2) and 18 C.F.R § 39.7(d).

http://www.nerc.com/

NERC Notice of Penalty Bonneville Power Administration December 30, 2019 Page 2


According to the Settlement Agreement, BPA does not contest the violation, and has agreed to other remedies and actions to mitigate the instant violation and facilitate future compliance under the terms and conditions of the Settlement Agreement. Statement of Findings Underlying the Violation This Notice of Penalty incorporates the findings and justifications set forth in the Settlement Agreement, by and between WECC and BPA. The details of the findings are set forth in the Settlement Agreement and herein. This Notice of Penalty filing contains the basis for approval of the terms of the Settlement Agreement by the NERC Board of Trustees Compliance Committee (NERC BOTCC). In accordance with Section 39.7 of the Commission’s regulations, 18 C.F.R. § 39.7 (2019), NERC provides the following summary table identifying each violation of a Reliability Standard resolved by the Settlement Agreement. Further information on the subject violation is set forth in the Settlement Agreement and herein.

NERC Violation ID Standard Req. VRF/VSL Applicable Function(s)

Discovery Method*

Violation Start-End

Date Risk Penalty

Amount

WECC2015015219 FAC-009-1 R1 Medium/Severe TO SR

9/11/2015 6/18/2007-3/15/2018 Serious No

Penalty FAC-009-1 R1 – OVERVIEW On September 11, 2015, BPA submitted a Self-Report after discovering that one of its current transformers (CT) was rated below the Facility Ratings of two associated transmission lines. BPA should have rated the CT as the most limiting element when BPA established Facility Ratings for the two lines. BPA’s Facility Ratings Methodology considered CT equipment to be sized such that it would never be the most limiting element in a Facility. Consequently, BPA’s Facility Rating database did not include any CT information, and its asset register did not include complete and accurate data concerning its CT equipment. WECC’s review and analysis of the violation revealed an increase in the extent of the violation. BPA had not identified CT equipment as the most limiting applicable element for at least 52 Facilities. WECC Enforcement determined BPA failed to determine Facility Ratings effectively under FAC-009-1 R1 and subsequent versions of the Standard and Requirement, including the current FAC-008-3 R6. Attachments A and B include additional facts regarding the violation.



The root cause of this violation was inadequate internal controls to ensure that BPA’s implementation of its Facility Ratings Methodology met all documented requirements. The violation posed a serious risk to the reliability of the bulk power system (BPS). BPA failed to establish Facility Ratings for its solely owned Facilities that were consistent with the associated Facility Ratings Methodology, when it did not account for 52 CTs as limiting series elements, as required by FAC-009-1 R1. These Facilities included transmission lines at 115 kV (22 lines), 161 kV (one line), 230 kV (25 lines), and 500 kV (four lines). At least six of the Facilities in scope are part of one or more WECC Major Transfer Paths. However, the mitigation resulted in derating of the affected Facilities by approximately ten percent. BPA did not have effective detective or preventive controls in place to detect or prevent this issue. However, as compensation, the first two transmission lines included in BPA’s Self-Report have not operated at Amps near a System Operating Limit (SOL). Additionally, BPA operates its system using conservative assumptions, not within close proximity to an SOL. Attachment A includes the facts regarding the violation that WECC considered in its risk assessment. BPA submitted its Mitigation Plan to address the referenced violation. Attachment C includes a description of the mitigation activities BPA took to address this violation. A copy of the Mitigation Plan is included as Attachment C. BPA certified that it had completed all mitigation activities. WECC verified that BPA had completed all mitigation activities as of June 14, 2018. Attachments A and E provide specific information on WECC’s verification of BPA’s completion of the activities. Regional Entity’s Basis for Resolution of the Violation According to the Settlement Agreement, WECC has assessed no penalty for the referenced violation. In reaching this determination, WECC considered the following factors:

1. BPA is a federal government entity, and WECC and NERC are bound to follow Southwestern Power Administration (SWPA) v. Federal Energy Regulatory Commission (FERC)5 in resolution of this matter;

2. The instant violation constitutes BPA’s first violation of the subject NERC Reliability Standard; 3. BPA self-reported the violation; 4. BPA cooperated during the enforcement action; 5. The violation posed a serious risk to the reliability of the BPS;

5 Sw. Power Admin. v. FERC, 763 F.3d 27 (D.C. Cir. 2014).



6. There was no evidence of any attempt to conceal the violation nor evidence of intent to do so; 7. The violation did not cause or extend a loss of load; and 8. There were no other mitigating or aggravating factors or extenuating circumstances that would

affect the disposition method. After consideration of the above factors, WECC determined that it would issue no penalty, in accordance with SWPA v. FERC. Statement Describing the Assessed Penalty, Sanction, or Enforcement Action Imposed6

Basis for Determination Taking into consideration the Commission’s direction in Order No. 693, the NERC Sanction Guidelines and the Commission’s July 3, 2008, October 26, 2009 and August 27, 2010 Guidance Orders,7 the NERC BOTCC reviewed the violation on December 12, 2019 and approved the resolution between WECC and BPA. In approving the resolution, the NERC BOTCC reviewed the applicable requirements of the Commission-approved Reliability Standards and the underlying facts and circumstances of the violation at issue. For the foregoing reasons, the NERC BOTCC approved the resolution and believes that the actions are appropriate for the violation and circumstances at issue, and is consistent with NERC’s goal to promote and ensure reliability of the BPS. Attachments to be Included as Part of this Notice of Penalty The attachments to be included as part of this Notice of Penalty are the following documents:

1. Settlement Agreement by and between WECC and BPA executed September 5, 2019, included as Attachment A;

2. BPA’s Self-Report for FAC-009-1 R1 dated September 11, 2015, included as Attachment B;

3. BPA’s Mitigation Plan designated as WECCMIT011937-1 for FAC-009-1 R1 submitted January 5, 2016, included as Attachment C;

6 See 18 C.F.R. § 39.7(d)(4).

7 N. Am. Elec. Reliability Corp., “Guidance Order on Reliability Notices of Penalty,” 124 FERC ¶ 61,015 (2008); N. Am. Elec. Reliability Corp., “Further Guidance Order on Reliability Notices of Penalty,” 129 FERC ¶ 61,069 (2009); N. Am. Elec. Reliability Corp., “Notice of No Further Review and Guidance Order,” 132 FERC ¶ 61,182 (2010).



4. BPA’s Certification of Mitigation Plan Completion for FAC-009-1 R1 submitted April 13, 2018, included as Attachment D; and

5. WECC’s Verification of Mitigation Plan Completion for FAC-009-1 R1 dated June 14, 2018, included as Attachment E.



Notices and Communications: Notices and communications with respect to this filing may be addressed to the following:

*Persons to be included on the Commission’s service list are indicated with an asterisk. NERC requests waiver of the Commission’s rules and regulations to permit the inclusion of more than two people on the service list. Melanie Frye* President and Chief Executive Officer Western Electricity Coordinating Council 155 North 400 West, Suite 200 Salt Lake City, UT 84103 (801) 883-6882 (801) 883-6894 – facsimile [email protected] Ruben Arredondo* Senior Legal Counsel Western Electricity Coordinating Council 155 North 400 West, Suite 200 Salt Lake City, UT 84103 (801) 819-7674 (801) 883-6894 – facsimile [email protected] Heather Laws* Director of Enforcement Western Electricity Coordinating Council 155 North 400 West, Suite 200 Salt Lake City, UT 84103 (801) 819-7642 (801) 883-6894 – facsimile [email protected]

Edwin G. Kichline* Senior Counsel and Director of Enforcement Oversight North American Electric Reliability Corporation 1325 G Street NW Suite 600 Washington, DC 20005 (202) 400-3000 (202) 644-8099 – facsimile [email protected] Alexander Kaplen* Associate Counsel North American Electric Reliability Corporation 1325 G Street NW Suite 600 Washington, DC 20005 (202) 400-3000 (202) 644-8099 – facsimile [email protected]



Jeff Cook* Acting VP Planning & Asset Management Bonneville Power Administration 5411 NE Highway 99 Vancouver, WA 98663 (360) 418-8981 [email protected] Mark Tucker* Supervisory Public Utilities Specialist Bonneville Power Administration 905 NE 11 Avenue Portland, OR 97232 360-418-8338 [email protected]



Conclusion NERC respectfully requests that the Commission accept this Notice of Penalty as compliant with its rules, regulations, and orders.

Respectfully submitted,

/s/ Alexander Kaplen Edwin G. Kichline Senior Counsel and Director of Enforcement Oversight Alexander Kaplen Associate Counsel North American Electric Reliability Corporation 1325 G Street NW Suite 600 Washington, DC 20005 (202) 400-3000 (202) 644-8099 - facsimile [email protected] [email protected]

cc: Bonneville Power Administration Western Electricity Coordinating Council Attachments

Attachment ASettlement Agreement by and between

WECC and BPA executed September 5, 2019

Expedited Settlement Agreement

Bonneville Power Administration

CF0975

August 16, 2019

2

The attached Expedited Settlement Agreement includes a summary of the facts and evidence supporting

each Alleged Violation, as well as other factors affecting disposition determination.

III. Proposed Penalty or Sanction

In Southwestern Power Admin. v. FERC1, the United States Court of Appeals for the District of Columbia

Circuit found, inter alia, that federal agencies are not subject to monetary penalties under Section 215 of

the Federal Power Act. Therefore, WECC cannot issue a monetary penalty against BPA.2

BPA’s compliance history, including this violation, may inform WECC’s future monitoring and

enforcement strategies. WECC considers the facts and circumstances related to a violation including, but

not limited to: 1) Violation Risk Factor; 2) Violation Severity Level; 3) risk to the reliability of the Bulk

Electric System (BES)3, including the seriousness of the violation; (4) Violation Time Horizon; 5) the

violation’s duration; 6) the Registered Entity’s compliance history; 7) the Registered Entity’s self-reports

and voluntary corrective action; 8) the degree and quality of cooperation by the Registered Entity in the

audit or investigation process, and in any remedial action; 9) the quality of the Registered Entity’s

compliance program; 10) any attempt by the Registered Entity to conceal the violation or any related

information; 11) whether the violation was intentional; 12) any other relevant information or extenuating

circumstances.

IV. Procedures for Registered Entity’s Response

If BPA accepts WECC’s proposal that the violation listed in the Agreement be processed through the

Expedited Settlement process, BPA must sign the attached Agreement and submit it through the WECC

Enhanced File Transfer (EFT) Server Enforcement folder within 15 calendar days from the date of this

Notice.

If BPA does not accept WECC’s proposal, BPA must submit a written rejection, through the EFT Server,

within 15 calendar days from the date of this Notice, informing WECC of the decision not to accept

WECC’s proposal.

1 763 F.3d 27 (D.C. Cir. 2014) 2 Id. 3 “The Commission, the ERO, and the Regional Entities will continue to enforce Reliability Standards for facilities that are included in the Bulk Electric System.” (Revision to Electric Reliability Organization Definition of Bulk Electric System, 113 FERC ¶ 61,150 at P 100 (Nov. 18, 2010))


Bonneville Power Administration

CF0975

August 16, 2019

3

If BPA rejects this proposal or does not respond within 15 calendar days, WECC will issue a Notice of

Alleged Violation.

V. Conclusion

In all correspondence, please provide the name and contact information of a BPA representative who is

authorized to address the above-listed Alleged Violation and who is responsible for providing the

required Mitigation Plan. Please also list the relevant NERC Violation Identification Number in any

correspondence.

Responses or questions regarding the Settlement Agreement should be directed to Katherine Bennett,

Enforcement Analyst, at 801-883-6850 or [email protected].

Respectfully submitted,

Heather M. Laws

Director, Enforcement

Attachment: Expedited Settlement Agreement

1

Attachment

EXPEDITED SETTLEMENT AGREEMENT

OF

WESTERN ELECTRICITY COORDINATING COUNCIL

AND

BONNEVILLE POWER ADMINISTRATION

Western Electricity Coordinating Council (WECC) and Bonneville Power Administration (BPA)

(individually a “Party” or collectively the “Parties”) agree to the following:

1. BPA does not contest the violation of the NERC Reliability Standard listed below.

2. The violation addressed herein will be considered a Confirmed Violation as set forth in the NERC

Rules of Procedure.

3. BPA has completed remediation and mitigation activities for the violation listed below.

4. The terms of this Settlement Agreement are subject to review and possible revision by NERC and

FERC. Upon NERC approval of the Settlement Agreement, NERC will file it with FERC and will

post it publicly. If either NERC or FERC rejects the Settlement Agreement, then WECC will

attempt to negotiate a revised Settlement Agreement with BPA that includes any changes to the

Settlement Agreement specified by NERC or FERC. If the Parties cannot reach a Settlement

Agreement, the CMEP governs the enforcement process.

5. The Parties have agreed to enter into this Settlement Agreement to avoid extended litigation with

respect to the matters described or referred to herein, to avoid uncertainty, and to effectuate a

complete and final resolution of the issues set forth herein. The Parties agree that this Settlement

Agreement is in the best interest of each Party and in the best interest of Bulk Power System (BPS)

reliability.

6. This Settlement Agreement represents a full and final disposition of the violation listed below,

subject to approval or modification by NERC and FERC. BPA waives its right to further hearings

and appeal; unless and only to the extent that BPA contends that any NERC or FERC action on

this Settlement Agreement contains one or more material modifications to this Settlement

Agreement.


2

7. In the event BPA fails to comply with any of the terms set forth in this Settlement Agreement,

WECC may initiate further enforcement actions against BPA to the maximum extent allowed by

federal law and the NERC Rules of Procedure. Except as otherwise specified in this Settlement

Agreement, BPA shall retain all rights to defend against such enforcement actions.

8. This Settlement Agreement shall be governed by and construed under federal law.

9. This Settlement Agreement contains the full and complete understanding of the Parties regarding

all matters set forth herein. The Parties agree that this Settlement Agreement reflects all terms and

conditions regarding all matters described herein and no other promises, oral or written, have

been made that are not reflected in this Settlement Agreement.

10. Each of the undersigned warrants that he or she is an authorized representative of the Party

identified, is authorized to bind such Party and accepts the Settlement Agreement on the Party’s

behalf.

11. The undersigned representative of each Party affirms that he or she has read the Settlement

Agreement, that all matters set forth in the Settlement Agreement are true and correct to the best

of his or her knowledge, information and belief, and that he or she understands that the

Settlement Agreement is entered into by such Party in express reliance on those representations.

12. This Settlement Agreement and all terms and stipulations set forth herein shall become effective

upon FERC’s approval of the Settlement Agreement by order or operation of law.

13. NOW, THEREFORE, in consideration of the terms set forth herein:

VIOLATION FACTS

I. NERC RELIABILITY STANDARD FAC-009-1 REQUIREMENT 1

NERC VIOLATION ID: WECC2015015219

WECC VIOLATION ID: WECC2015-613962

STANDARD

1. NERC Reliability Standard FAC-009-1 Requirement 1 states:

R1. The Transmission Owner and Generator Owner shall each establish Facility Ratings for its

solely and jointly owned Facilities that are consistent with the associated Facility Ratings

Methodology.


3

2. On September 11, 2015, the entity submitted a Self-Report stating that, as a Transmission Owner

(TO), it was in noncompliance with FAC-008-3 R6. During an internal review, the entity

discovered that one of its current transformers (CT) was rated below the Facility Ratings of two

associated transmission lines. The CTs should have been rated as the most limiting element when

the entity established Facility Ratings for the two lines. The entity’s Facility Ratings Methodology

at this time considered CT equipment to be sized such that it would never be the most limiting

element in a Facility. Consequently, the entity’s Facility Rating database did not include any CT

information and its asset register did not include complete and accurate data concerning its CT

equipment.

3. WECC’s review and analysis of the violation revealed an increase in the scope of the violation,

which prompted an entity-initiated program-wide review of its Facility Ratings throughout its

footprint, which had not identified CT equipment as the most limiting applicable element, for at

least 52 of its Facilities. These Facilities included transmission lines at 115kV (22 lines), 161kV (one

line), 230kV (25 lines), and 500kV (four lines). At least six of the Facilities in scope are part of one

or more WECC Major Transfer Paths. The root cause of this violation was attributed to less than

adequate internal controls to ensure the entity’s implementation of Facility Ratings Methodology

met all documented requirements. This violation began on June 18, 2007, when FAC-009-1 R1

became mandatory and enforceable and ended on March 15, 2018, when the entity revised its

Facility Ratings Methodology to include CT equipment as the most limiting element, for a total

of 3,923 days of noncompliance.

4. After reviewing all relevant information, WECC Enforcement determined the entity failed to

effectively perform FAC-009-1 R1 and subsequent versions of the Standard and Requirement,

including the current FAC-008-3 R6.

RELIABILITY RISK ASSESSMENT

5. WECC determined this violation posed a serious and substantial risk to the reliability of the Bulk

Power System (BPS). In this instance, the entity failed to establish Facility Ratings for its solely

owned Facilities that are consistent with the associated Facility Ratings Methodology, when it did

not account for 52 CTs as a limiting series element, as required by FAC-009-1 R1. These Facilities

included transmission lines at 115kV (22 lines), 161kV (one line), 230kV (25 lines), and 500kV (four

lines). At least six of the Facilities in scope are part of one or more WECC Major Transfer Paths.

6. The entity did not have effective detective or preventative controls in place to detect or prevent

this issue. However, as a compensation, the first two transmission lines included in the entity’s

Self-Report have not operated at Amps near an System Operating Limit (SOL). Additionally,


4

the entity operates its system using conservative assumptions, not within close proximity to an

SOL.

REMEDIATION AND MITIGATION

7. On January 5, 2016, the entity submitted a Mitigation Plan to address this violation, and upon

expanding its internal investigation to include a program-wide review, submitted a revised

Mitigation Plan on April 24, 2017. WECC accepted the revised Mitigation Plan on May 5, 2017.

8. To remediate and mitigate this violation, the entity:

a. established a methodology to determine normal ratings for all types of CTs, with

documented instructions for collecting nameplate data, documenting in-service ratios and

calculating ratings for operating temperatures;

b. investigated extent of condition across its entire footprint, both with respect to CT

equipment and all other Facility Elements, including multiple reviews by management

and subject-matter experts;

c. revised language concerning CT equipment in its Facility Ratings Methodology;

d. designated and coordinated responsibility for collection, application, analysis, and

validation of CT equipment data;

e. established to Information Owners, Information System Owners, and data stewards for

Facility Rating systems;

f. implemented an internal Facility Ratings tool with controls to ensure equipment ratings

are complete and accurate;

g. identified affected Facility Ratings by incorporating CTs as a limiting element category in

its asset register, rating database and internal tool; and

h. verified its Facility Rating Report and tool reflect limiting equipment accurately.

9. On April 13, 2018, the entity submitted a Mitigation Plan Completion Certification and on June

14, 2018, WECC verified the completion of its Mitigation Plan.

OTHER FACTORS AFFECTING DISPOSITION DETERMINATION

10. No monetary penalties. BPA is a federal entity and not subject to monetary penalties.4

11. However, WECC determined that the Expedited Settlement disposition option is appropriate for

the following reasons:

a. Base factors:

i. The Violation Risk Factor is Medium and the Violation Severity Level is Moderate

for this violation.

ii. This violation posed serious and substantial risk to the reliability of the BPS.

4 See Southwestern Power Admin. v. FERC, 763 F.3d 27 (D.C. Cir. 2014).


5

iii. The violation duration was 3,923 days as described above.

iv. This Requirement has an Operations Planning violation time horizon expectation

for remediation of the Requirement from day-ahead up to and including seasonal

to preserve the reliability of the BPS.

b. WECC applied a mitigating factor for the following reasons:

i. The entity was cooperative throughout the process.

ii. The entity self-reported this violation in a timely manner, 46 days from the date of

discovery.

iii. The entity agreed to settle this violation and not go to hearing.

c. Other Considerations:

i. WECC did not apply mitigating credit for the entity’s Internal Compliance

Program (ICP). Although the entity does have a documented ICP, WECC

determined that it was not effective in detecting this violation.

ii. WECC determined that there was no relevant compliance history for this violation.

iii. The entity did not fail to complete any applicable compliance directives. There was

no evidence of any attempt by the entity to conceal the violation. There was no

evidence that violation was intentional. The entity submitted all requested

documentation and/or mitigation plans timely.

[Remainder of page intentionally left blank - signatures affixed to following page]

Attachment BBPA's Self-Report of Violation of FAC-009-1 R1

submitted September 11, 2015

Western Electricity Coordinating Council

September 11, 2015

Self Report

Entity Name: Bonneville Power Administration (BPA)

NERC ID: NCR05032

Standard: FAC-008-3

Requirement: FAC-008-3 R6.

September 11, 2015

Has this violation previouslybeen reported or discovered?:

No

Date Submitted:

Entity Information:Joint Registration

Organization (JRO) ID:

Coordinated FunctionalRegistration (CFR) ID:

Contact Name: Jenifur Rancourt

Contact Phone: 5032303672

Contact Email: [email protected]

Violation:Violation Start Date: January 01, 2013

End/Expected End Date:

Region Initially Determined aViolation On:

Reliability Functions: Transmission Owner (TO)

Is Possible Violation stilloccurring?:

Yes

Number of Instances: 1

Has this Possible Violationbeen reported to other

Regions?:

No

Which Regions:

Date Reported to Regions:

Detailed Description andCause of Possible Violation:

Note: Number of Instances is currently unknown. WECC system would notallow this input so left at 1.

Detailed Description and Cause of Possible Violation: A BPA team reviewingthe interchange on the Maple Valley - Talbot #1 and #2 lines found that the CTwas rated below the full facility ratings of the two lines. BPA's Facility RatingMethodology at the time of the discovery stated that CTs are sized such thatthey are not the most limiting element in a facility, and as a result, CTs are notincluded in Facility Ratings. It also stated that "Facility Rating[s] shall respectthe most limiting applicable Equipment Rating of the individual equipment thatcomprises that Facility." In this case, the Maple Valley - Talbot #1 and #2 lineswere rated 3268 Amps and the CTs were rated 3000 Amps. Since the CTswere rated lower than the lines, it was determined that the CTs should havebeen identified as the most limiting element on each line. BPA determined thatthis was a violation of FAC-008 R6.

Mitigating Activities:Description of Mitigating

Activities and PreventativeMeasure:

BPA revised its Facility Ratings Methodology on 7/28/15 to remove thestatement that CTs are sized to not be the most limiting element. In addition,SCADA limits have been set at 2715 Amps for both lines. BPA has initiated aproject to determine the ratings of all CTs on BPA's system and to integrate

Page 1 of 2 09/11/2015


September 11, 2015

Self Report

that data into its facility ratings database. While we have no reason to believethat the non-compliance extends beyond CTs, BPA will investigate otherequipment types as well to ensure that our facility ratings are complete andaccurate.

Date Mitigating ActivitiesCompleted:

Have Mitigating Activitiesbeen Completed?

No

Impact and Risk Assessment:

Description of Potential andActual Impact to BPS:

Potential impact: BPA is still investigating the scope of the CT issue and hasnot yet determined the number of facility ratings that will need to be adjusted.

Actual impact: In the case of the Maple Valley - Talbot #1 and #2 lines, thelines had never been operated at or near the limit of the CTs. Since January 1,2006, the Maple Valley - Talbot #1 line has never been operated above 1500Amps. Since January 1, 2006, the Maple Valley - Talbot #2 line has neverbeen operated above 2200 Amps.

Minimal

Moderate

Actual Impact to BPS:

Potential Impact to BPS:

Risk Assessment of Impact toBPS:

BPA is working to determine the scope of this violation as quickly as possiblein order to accurately assess the impact on the BES and make any necessarycorrections.

Additional Entity Comments: BPA intends to submit Mitigation Plan ID P220 on or around October 15, 2015.

CommentFrom User Name

Additional Comments

No Comments

No Documents

Additional Documents

Size in BytesFrom Document Name Description

Page 2 of 2 09/11/2015

Attachment CBPA's Mitigation Plan designated as WECCMIT011937-1

for FAC-009-1 R1 submitted January 5, 2016


April 05, 2016

Mitigation Plan

Bonneville Power AdministrationRegistered Entity:

Mitigation Plan Summary

Mitigation Plan Code:

Mitigation Plan Version:

WECCMIT011937

1

RequirementNERC Violation ID Violation Validated On

WECC2015015219 FAC-008-3 R6. 01/26/2016

Mitigation Plan Accepted On: April 01, 2016

NoMitigation Plan Completed? (Yes/No):

Mitigation Plan Submitted On: January 05, 2016

Mitigation Plan Proposed Completion Date: February 15, 2017

Mitigation Plan Certified Complete by BPA On:

Mitigation Plan Completion Verified by WECC On:

Actual Completion Date of Mitigation Plan:

9Page 1 of 04/05/2016


April 05, 2016

Compliance Notices

Section 6.2 of the NERC CMEP sets forth the information that must be included in a Mitigation Plan. TheMitigation Plan must include:

(1) The Registered Entity's point of contact for the Mitigation Plan, who shall be a person (i) responsible for filingthe Mitigation Plan, (ii) technically knowledgeable regarding the Mitigation Plan, and (iii) authorized andcompetent to respond to questions regarding the status of the Mitigation Plan. This person may be theRegistered Entity's point of contact described in Section B.(2) The Alleged or Confirmed Violation(s) of Reliability Standard(s) the Mitigation Plan will correct.(3) The cause of the Alleged or Confirmed Violation(s).(4) The Registered Entity's action plan to correct the Alleged or Confirmed Violation(s).(5) The Registered Entity's action plan to prevent recurrence of the Alleged or Confirmed violation(s).(6) The anticipated impact of the Mitigation Plan on the bulk power system reliability and an action plan tomitigate any increased risk to the reliability of the bulk power-system while the Mitigation Plan is beingimplemented.(7) A timetable for completion of the Mitigation Plan including the completion date by which the Mitigation Planwill be fully implemented and the Alleged or Confirmed Violation(s) corrected.(8) Implementation milestones no more than three (3) months apart for Mitigation Plans with expectedcompletion dates more than three (3) months from the date of submission. Additional violations could bedetermined or recommended to the applicable governmental authorities for not completing work associated withaccepted milestones.(9) Any other information deemed necessary or appropriate.(10) The Mitigation Plan shall be signed by an officer, employee, attorney or other authorized representative ofthe Registered Entity, which if applicable, shall be the person that signed the Self Certification or Self Reportingsubmittals.(11) This submittal form may be used to provide a required Mitigation Plan for review and approval by regionalentity(ies) and NERC.

• The Mitigation Plan shall be submitted to the regional entity(ies) and NERC as confidential information inaccordance with Section 1500 of the NERC Rules of Procedure.

• This Mitigation Plan form may be used to address one or more related alleged or confirmed violations of oneReliability Standard. A separate mitigation plan is required to address alleged or confirmed violations withrespect to each additional Reliability Standard, as applicable.

• If the Mitigation Plan is accepted by regional entity(ies) and approved by NERC, a copy of this Mitigation Planwill be provided to the Federal Energy Regulatory Commission or filed with the applicable governmentalauthorities for approval in Canada.

• Regional Entity(ies) or NERC may reject Mitigation Plans that they determine to be incomplete or inadequate.

• Remedial action directives also may be issued as necessary to ensure reliability of the bulk power system.

• The user has read and accepts the conditions set forth in these Compliance Notices.

9Page 2 of 04/05/2016


April 05, 2016

Identify the individual in your organization who will serve as the Contact to the Regional Entity regardingthis Mitigation Plan. This person shall be technically knowledgeable regarding this Mitigation Plan andauthorized to respond to Regional Entity regarding this Mitigation Plan:

Name:

Title:

Email:

Phone:

Jenifur Rancourt

Supervisory Public Utility Specialist

[email protected]

503-230-3672

Address: 905 NE 11 AvenuePortland OR 97232

Entity Information

Identify your organization:

Entity Name: Bonneville Power Administration

NCR05032NERC Compliance Registry ID:

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April 05, 2016

Violation(s)

This Mitigation Plan is associated with the following violation(s) of the reliability standard listed below:

RequirementViolation ID Date of Violation

Requirement Description

WECC2015015219 01/01/2013 FAC-008-3 R6.

Each Transmission Owner and Generator Owner shall have Facility Ratings for its solely and jointly owned Facilitiesthat are consistent with the associated Facility Ratings methodology or documentation for determining its FacilityRatings.

Brief summary including the cause of the violation(s) and mechanism in which it was identified:

A team reviewing the interchange between BPA and Puget Sound Energy (PSE) on the Maple Valley – Talbot#1 and #2 lines found that the Current Transformer (CT) was rated below the full facility ratings of the twolines. BPA’s Facility Rating Methodology at the time of the discovery stated that CTs are sized such thatthey are not the most limiting element in a facility, and as a result, CTs are not included in Facility Ratings.It also stated that “Facility Rating[s] shall respect the most limiting applicable Equipment Rating of theindividual equipment that comprises that Facility.” In this case, the Maple Valley – Talbot #1 and #2 lineswere rated 3268 Amps and the CTs were rated 3000 Amps. Since the CTs were rated lower than the lines,it was determined that the CTs should have been identified as the most limiting element on each line. BPAdetermined that this was a violation of FAC-008 R6.

Relevant information regarding the identification of the violation(s):

BPA’s facility rating database does not currently contain data on CT ratings, and BPA’s asset register(Cascade) has incomplete data about CTs. Confirming the CT ratings in this case involved gathering datafrom the nameplates of the CTs themselves. The full mitigation of this issue will involve similar effort on amuch larger scale to confirm CT ratings throughout BPA’s footprint.

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April 05, 2016

Plan Details

1. Document methodology for determining ratings for all types of CTs2. Research other device types to determine if any other similar issues exist3. Assign personnel to collect all needed data4. Establish Information Owners (IO), Information System Owner (ISO) and data stewards forappropriate facility rating systems5. Begin recording CT data in appropriate repository6. Record CT ratings in Facility Ratings database and begin validation7. Deploy Facility Ratings database tool8. Create and implement action plans to correct issues found with Facility Ratings. (If this requiresreplacing equipment, the fix may extend beyond the completion date of this mitigation plan.)

Identify and describe the action plan, including specific tasks and actions that your organization isproposing to undertake, or which it undertook if this Mitigation Plan has been completed, to correct theviolation(s) identified above in Section C.1 of this form:

Provide the timetable for completion of the Mitigation Plan, including the completion date by which theMitigation Plan will be fully implemented and the violations associated with this Mitigation Plan arecorrected:

February 15, 2017Proposed Completion date of Mitigation Plan:

Milestone Activities, with completion dates, that your organization is proposing for this Mitigation Plan:

Milestone Activity

*ProposedCompletion Date

(Shall not be greaterthan 3 months apart)

ActualCompletion

DateDescriptionEntity Comment on

Milestone Completion

ExtensionRequestPending

02/15/2016February 15, 2016: • Documentmethodology fordetermining ratingsfor all types of CTs• Research otherdevice types todetermine if anyother similar issuesexist• Assign personnel tocollect all neededdata

02/12/2015 Milestone - Documentmethodology fordetermining ratings for alltypes of CTs:Refer to document titledMethodology forDetermining Ratings forBPA CurrentTransformers_Feb15.

Milestone - Research otherdevice types to determine ifany other similar issuesexist:This milestone was met intwo key ways. First, BPA’sFacility Rating MethodologyStandard, STD-D-000011,was revised after discoveryof the issue related toratings of currenttransformers (CTs). BPAhas a rigorous standardsreview and approval

No

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April 05, 2016

Milestone Activity



ActualCompletion




process that includes in-person meetings withmultiple subject matterexperts to propose and vetchanges to the standard,followed by review andapproval by a larger groupof experts includingmanagers. STD-D-000011was revised in July 2015 tomake changes to the CTrating section and again inSeptember 2015 to makeanother, unrelated change.During these reviews, noother gaps or similar issueswere identified.In addition, the project teamworking on this mitigationplan has met multiple timessince July 2015 to discussmany topics, including otherequipment types that couldalso represent gaps inBPA’s facility rating data.No other issues have beenidentified. If another gap isidentified, it will beinvestigated and added tothe scope of this project asnecessary.

Milestone - Assignpersonnel to collect allneeded data:This mitigation plan willinvolve a coordinate effort toinclude research ofdocumentation by theTransmission Engineering(TE) organization andcollection of data fromdevices by theTransmission Field Services(TF) organization.

05/15/2016May 15, 2016 Begin recording CT No

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April 05, 2016

Milestone Activity



ActualCompletion




data in appropriaterepository

08/15/2016August 15, 2016 Establish InformationOwners (IO),Information SystemOwner (ISO) anddata stewards forappropriate facilityrating systems

No

11/15/2016November 15, 2016: Record CT ratings inFacility Ratingsdatabase and beginvalidation

No

02/15/2017February 15, 2017 • Deploy FacilityRating database tool• Create andimplement actionplans to correctissues found withFacility Ratings

No

Additional Relevant Information

P220

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April 05, 2016

Reliability Risk

Reliability Risk

While the Mitigation Plan is being implemented, the reliability of the bulk Power System mayremain at higher Risk or be otherwise negatively impacted until the plan is successfully completed. To the extentthey are known or anticipated : (i) Identify any such risks or impacts, and; (ii) discuss any actions planned orproposed to address these risks or impacts.

It is likely additional Facility Ratings violations exist on BPA Facilities. As these violations are found, BPA willmitigate the issue as quickly as possible. BPA operates its system using conservative assumptions and mostof the time not within close proximity to a System Operating Limit. This will help mitigate the risk to thesystem from any adverse impacts of unidentified facility limits. There are no known reliability issues thathave resulted due to Facility Ratings.

Prevention

At the completion of this mitigation plan, BPA will have complete equipment ratings in Cascade and a robustdatabase that will contain BPA’s complete Facility Ratings. Analysis of ratings will be much easier in thefuture so that we can prevent recurrence.

Describe how successful completion of this plan will prevent or minimize the probability further violations of thesame or similar reliability standards requirements will occur

Procedures will be developed to keep equipment ratings up to date in Cascade.

Describe any action that may be taken or planned beyond that listed in the mitigation plan, to prevent or minimizethe probability of incurring further violations of the same or similar standards requirements

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April 05, 2016

Authorization

An authorized individual must sign and date the signature page. By doing so, this individual, on behalf ofyour organization:

* Submits the Mitigation Plan, as presented, to the regional entity for acceptance and approval by NERC, and

* if applicable, certifies that the Mitigation Plan, as presented, was completed as specified.

Acknowledges:

1. I am qualified to sign this mitigation plan on behalf of my organization.

2.

3. I have read and am familiar with the contents of the foregoing Mitigation Plan.

Plan, including the timetable completion date, as accepted by the Regional Entity, NERC,and if required, the applicable governmental authority.

Name:

Title:

Authorized On:

Jeffrey W. Cook

VP, Planning and Asset Management

January 04, 2016

Bonneville Power Administration Agrees to be bound by, and comply with, this Mitigation

Authorized Individual Signature:

(Electronic signature was received by the Regional Office via CDMS. For Electronic Signature Policy see CMEP.)

Authorized Individual

I have read and understand the obligations to comply with the mitigation plan requirements and EROremedial action directives as well as ERO documents, including but not limited to, the NERC rules ofprocedure and the application NERC CMEP.

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Attachment DBPA's Certification of Mitigation Completion for

FAC-009-1 R1 submitted on April 13, 2018


June 18, 2018

Certification of Mitigation Plan Completion

Submittal of a Certification of Mitigation Plan Completion shall include data or information sufficient for theRegional Entity to verify completion of the Mitigation Plan. The Regional Entity may request additional data orinformation and conduct follow-up assessments, on-site or other Spot Checking, or Compliance Audits as it deemsnecessary to verify that all required actions in the Mitigation Plan have been completed and the Registered Entityis in compliance with the subject Reliability Standard. (CMEP Section 6.6)

Bonneville Power AdministrationRegistered Entity Name:

WECC2015015219

NERC Registry ID: NCR05032

NERC Violation ID(s):

FAC-008-3 R6.Mitigated Standard Requirement(s):

March 23, 2018

Scheduled Completion as per Accepted Mitigation Plan:

Mitigation completed on 3/23/2018.Entity Comment:

Date Mitigation Plan completed:

May 15, 2018

April 13, 2018WECC Notified of Completion on Date:

Document Name Description Size in BytesFrom

Additional Documents

FAC-008 R6 Mitigation PlanRevised 12-29.pdf

368,624Entity

FAC-008 R6 Mitigation PlanRevised 04-16-17.pdf

171,508Entity

FAC-008 R6 Mitigation PlanCMP 04-04-2018.pdf WECCMIT2015-005583-1 Certification of Mitigation

Completion PDF with supporting evidence.

18,026,579Entity

I certify that the Mitigation Plan for the above named violation(s) has been completed on the date shown aboveand that all submitted information is complete and correct to the best of my knowledge.

[email protected]

Title:

Name:

Phone:

Email:

1 (360) 418-8981

Jeffrey W. Cook

VP, Planning and Asset Management

(Electronic signature was received by the Regional Office via CDMS. For Electronic Signature Policy see CMEP.)

Authorized Signature Date

1Page 1 of 06/18/2018

Attachment EVerification of Mitigation Plan Completion for

FAC-009-1 R1 dated June 14, 2018